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Legal Briefing
UK tax treatment of US LLCs – the HMRC’s response to the Swift case
Practice Area: Corporation Tax
Sector: Business services
Jurisdiction: USA
Published: 02 June 2010
Law Firm: Baker & McKenzie
Overview
HM Revenue & Customs has published its response to the recent decision of the UK’s First-tier Tribunal in the Swift v HMRC case, which concerned the UK tax treatment of a US limited liability company (LLC).
This will be relevant to UK or US parented corporate groups, or to private equity or hedge fund structures, which include an LLC entity.
The decision had caused uncertainty regarding the correct UK tax treatment of US LLCs and appeared to undermine HMRC’s published practice.
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